Republic of the Philippines

SUPREME COURT OF THE PHILIPPINES

FOURTH JUDICIAL REGION
REGIONAL TRIAL COURT
BRANCH ________
San Jose, Occidental Mindoro

PEOPLE OF THE PHILIPPINES, CRIM. CASE NO. R-8618-8619

Plaintiff,

-versus- -for-
______________________________ VIOLATION OF SEC 11 & 12,
Accused ARTICLE II, RA 9165

x---------------------------------------------------x

MOTION FOR REDUCTION OF BAILBOND

COMES NOW, the accused, through counsel, unto this Honorable

Court, most respectfully avers;

1. That accused was charged of the aforementioned cases and bail

was set for her temporary liberty in the amount of two hundred
thousand pesos (P200,000.00) for Criminal Case No. R-8618, and
sixty thousand pesos (60,000.00) for Criminal Case No. R-8619,
respectively;

2. That upon motion of the accused the Honorable Court reduced the
amount of bail in Criminal Case No. R-8618 from Two Hundred
Thousand Pesos (P200,000.00) to One Hundred Thousand Pesos
(P100,000.00); and in Criminal Case No. R-8619 from Sixty
Thousand Pesos (P60,000.00) to Thirty Thousand Pesos
(P30,000.00).

3. That notwithstanding the bail being reduced to the aforementioned

amounts, and despite much effort from the accused and her family,
she is still unable to gather enough resources to put up the said
bail;

4. That accused has no profitable business, vocation or occupation.

She relies only on the goodwill and charity of her children to live.

5. That accused is already old and sickly and her children are anxious
that because of extreme weather condition nowadays, her immune
system may not be able to coped up;
 6. That if the accuse will be allowed to post bail to a much lower
amount, she will no longer reside in Caminawit; she will stay at her
daughter’s place in Brgy. Central instead;

7. That accused is a first time offender, she has no records in their

baranggay nor in the police station for any other case except this
case;

8. That the family of the accused are all residents of this municipality
thus possibility of fight and hiding is very nil;

9. That after pooling together all the resources of her family, accused
was only able to raise the amount of One Hundred Thousand
Pesos (P100,000.00); it is with this amount that accused knocks at
the magnanimous heart of this Honorable Court seeking that the
bail bond of the accused be further reduced to such affordable
amount so that she could enjoy her temporary liberty pending the
final disposition of this case;

WHEREFORE, premises considered, it is most respectfully prayed

for that in the higher interest of justice the bailbond of the accused be
reduce for Criminal Case No. R-8618 from ONE HUNDRED THOUSAND
PESOS (Php 100,000.00) to EIGHTY THOUSAND PESOS
(Php80,000.00) and for Criminal Case No. R-8619 from THIRTY
THOUSAND PESOS (PHP30,000.00) to TWENTY THOUSAND PESOS
(Php20,000.00). Such other reliefs as are just and equitable under the
circumstances are likewise prayed for.

San Jose, Occidental Mindoro, 04 May 2018.

FOR THE ACCUSED

_______________________________________
Counsel for the Accused

The Clerk of Court

Regional Trial Court
Branch ________
San Jose, Occidental Mindoro

Please submit the foregoing motion upon receipt for consideration of the
Honorable Court without further argument.
 Thank you.

_____________________________
Copy Furnished:
The Provincial Prosecutor
Office of the Provincial Prosecutor
San Jose, Occidental Mindoro